IR 05000483/1996007

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/96-07

ML20129E261
Person / Time
Site:	Callaway
Issue date:	10/23/1996
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Schnell D UNION ELECTRIC CO.
References
NUDOCS 9610280003
Download: ML20129E261 (4)

Text

{{#Wiki_filter:.. .- . - . . _~ . _ - -. .

+        1
,

'

, / "4 4, 4   UNITED STATES f\,, ,A  NUCLEAR REGULATORY COMMISSION
'
'-*
$    REGloN IV 611 RYAN PLAZA oRIVE, sulTE 400
*['A . . . . . /, $M[[

j

'

AR LtNGToN. TEXAS 76011-8064 OCT 231996 Donald F. Schnell, Senior Vice President - Nuclear Union Electric Company P.O. Box 149 St. Louis, Missouri 63166 SUBJECT: NRC INSPECTION REPORT 50-483/96-07 Thank you for your letter of October 7,1996,in response to our letter and Notice of Violation dated September 9,1996. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, '.L h a h J. E. Dyer, Director  ! Division of Reactor Projects Docket No.: 50-483 License No.: NPF-30 cc: Professional Nuclear Consulting, In Raines Drive  ; Derwood, Maryland 20855 Gerald Charnoff, Es \ \' Thomas A. Baxter, Es Shaw, Pittman, Potts & Trowbridge ,t 2300 N. Street, ' Washington, D.C. 20037

  "

9610290003 961023 PDR ADOCK 05000483 G PDR

,
,

l '

,    l

Union Electric Company -2-H. D. Bono, Supervising Engineer Site Licensing j Union Electric Company l P.O. Box 620 Fulton, Missouri 65251 G. L. Randolph, Vice President Nuclear Operations Union Electric Company  ; P.O. Box 620 i Fulton, Missouri 65251 I Manager - Electric Department Missouri Public Service Commission 301 W. High-P.O. Box 360 .i Jefferson City,.. Missouri 65102 Ronald A. Kucera, Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 Neil S. Carns, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839  ! Dan I. Bolef, President Kay Drey, Representative Board of Directors Coalition l for the Environment

   "

6267 Delmar Boulevard University City, Missouri 63130 Lee Fritz, Presiding Commissioner i Callaway County Court House . 10 East Fifth Street Fulton, Missouri 65151

  ._
*
.
>

Union Electric Company -3-Alan C. Passwater, Manager Licensing and Fuels Union Electric Company P.O. Box 149 St. Louis, Missouri 63166

  :

J. V. Laux, Manager Quality Assurance Union Electric Company P.O. Box 620 Fulton, Missouri 65251 l l l

l l

  <

i I

  . _ _ _

_ _ _ _ _ _ _ _ _ - _ . o OCT 2 31996 Union Electric Company -4-bec~to DMB (IE01) bec distrib. by RIV: L. J. Callan Resident inspector DRP Director DRS-PSB Branch Chief (DRP/B) MIS System Project Engineer (DRP/B) RIV File Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10) DOCUMENT NAME: R:\_CW\CW607AK.DGP To receive copy of docurnent, Indicate in box: "C" = Copy wahout enclosures "E" = Copy wth enclosures "N" = No copy PE:DRP/B l C:DRP/B l D:DRP pJ f ! l l DNGraves:cm ,, WDJohnsonjr3 JEDyerP f 10/ 3)/96 f 10/ L3 /96 F 10/23 /96 OFFICIAL RECORD COPY 280002

_ _ _ _ _ . . _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - _ _ _

        ..
,

, OCT 2 31996 Union Electric Company -4-bec to DMB (IE01) bec distrib. by RIV: L. J. Callan Resident inspector DRP Director DRS-PSB Branch Chief (DRP/B) MIS System Project Engineer (DRP/B) RIV File Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10) DOCUMENT NAME: R:\_CW\CW607AK.DGP To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy PE:DRP/B C:DRP/B D:DRP df l DNGraves:cm 3 WDJohnsonp3 JEDyer P f'

 '

10/ 1,)/96 10/ L3 /96 F 10/23 /96 OFFICIAL RECORD COPY G $$Y{$$ o

*
.
'
#. 1901 Chouteau Avem,e
 , Post OMce Box 149
, . St. Louis. Missouri 63166
'

314 554-2650 i

   -

i __ _

    ~
    ~~

UNION Donald F. Schnell Etscraic uar ; e s .,

     .

ig,',ya ??"~"t

 'ggOctober 7,1996    -
;    }
    -

_ ]: U. S. Nuclear Regulatory Commission ! Attn: Document ControlDesk

Mail Stop Pl-137

, Washington, DC 20555-0001 ULNRC-3438

Gentlemen:

        )

i REPLY TO NOTICE OF VIOLATION j INSPECTION REPORT NO. 50-483/96007  ! CALLAWAY PLANT ! This responds to Mr J. E. Dyer's letter dated September 9,1996, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/96007. Our response to the violation is presented in the attachmen None of the material in the response is considered proprietary by Union Electri If you have any questions regarding this response, or if additional information is required, please let me kno Very tmly yours, Donald F. Schnell i DFS/tmw Attachment: 1) Response to Violation i f7-sy/ cyo&ost ee .

_ - - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ .. _

            .-
            *

ULNRC-3438 .

            '

October 7,1996 , Page 2 , l l cc: Mr. L. Joe Callan Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman,MO 65077 Ms. Kristine M. Thomas (2 copies) Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation

U. S. Nuclear Regulatory Comnussion Mail Stop 13E16 i Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street Washington, DC 20037 Manager, Plant Support Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington,KS 66839 I y

     .- _ _ _ _ . _ _ _ _ . _ _ _ _ _ . . . . _ _ . - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.
.h
.
'
. " Attachm:nt to
-

ULNRC-3438 October 7,1996 Page1 Statement of Violation During an NRC inspection conducted on July 21 through August 31,1996, one violation ofNRC requirements was identified. In accordance with the " General Statement ofPolicy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below: , Callaway Plant Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 197 Regulatory Guide 1.33, Appendix A, l.d, requires administrative procedures for procedure adherence and temporary change Administrative Procedure APA-ZZ-00100," Procedure Adherence," Revision 11, Step 4.2.1, states, in part, that continuous use procedures must be performed exactly as written. Additionally, APA-ZZ-00100, Step 4.2.6 states, in part, that variance from the guidance contained within a continuous use procedure requires a procedure revision or temporary chang Contrary to the above, the licensee failed to adhere to the requirements of Procedure APA-ZZ-00100 on two occasions: On August 9,1996, during the performance of the local pre-start checks on Emergency Diesel Generator A, plant operators identified that lube oil temperature was outside the required range specified in Procedure OSP-NE-0001 A, " Standby Diesel Generator A Periodic Tests," Revision 0, Step 6.1.7. Procedure OSP-NE-0001 A was classified as a continuous use procedur Plant operators proceeded with the test without changing the procedur . On August 23,1996, during the performance of solid state protection system testing, instmment and control technicians failed to use retractable sheathed banana plug test leads as specified by Procedure ISF-SB-00A32, " Solid State Protection System Functional Test, Revision 14, Step 6.6.4. Procedure ISF-SB-00A32 was classified as a continuous use procedur This is a Severity Level IV violation (Supplement 1).

I t I a

-

      .

t

      % ,e Attachment to      -
      -

ULNRC-3438  ? October 7,1996 Page 2 Reason for the Violation

+ 1st Example The Shift Supervisor recognized the procedure deficiency and determined a procedure revision was required. A procedure revision was initiated. However, the Shin Supervisor did not understand that the approved procedure revision had to be issued for use prior to continuation of the surveillance tes . 2nd Example The I&C technician did not comply with the caution statement prior to step 6. performance. Two caution statements were listed, the second of which actually included a third caution. The third warned of the need to use retractable sheathed banana plug test leads to prevent a potential undesired Engineered Safe:y Feature Actuatio Corrective Steps Taken and Results Achieved:
* 1st Example Procedure OSP-NE-0001 A has been revised to increase the slowable tube oil temperature band to account for the operational characteristics of the lube oil heate * 2nd Example When identified by the inspector, the I&C technician stopped, corrected himself, obtained the correct equipment and completed the task without incident. In addition, a revision to ISF-SB-00A32, " Solid State Protection System Functional Test" has been initiate Corrective Steps to Avoid Further Violations:
'

Management expectations for continuous use procedure adherence were reinforced by the Superintendent, Operations with the shin licensed senior reactor operators and by the General Supeivisor I&C with the I&C department. The requirement to perform continuous use procedures exactly as written was stressed. The training also stressed that variance from a continuous use procedure requires completion of an approved procedure revision or temporary change prior to continuing performance of the procedur Date when Full Compliance will be Achieved: Full compliance was achieved on September 26,199 t l }}